James Steinle v. United States, 20-15419

BLM ranger John Woychowski parked a personal car in San Francisco on June 27, 2015 and left a loaded, BLM‑issued Sig Sauer P239 in a backpack inside the vehicle without the issued trigger lock.
The car was broken into that night; the backpack was recovered but the pistol was not.
Four days later (July 1, 2015) Juan Francisco Lopez‑Sanchez found the pistol wrapped in cloth on Pier 14, picked it up, fired it, and a ricocheted bullet killed Kathryn Steinle.
Plaintiffs sued the United States under the Federal Tort Claims Act, alleging Woychowski’s negligent storage of the firearm. The district court granted summary judgment for the U.S. (no duty and no proximate causation).
The Ninth Circuit affirmed solely on proximate‑cause grounds, applying California tort law and holding the chain of events too attenuated as a matter of law to impose liability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Woychowski owed a duty of care to Ms. Steinle	Woychowski negligently left a loaded, unsecured government firearm in an unattended car in an urban area, creating foreseeable risk	Either no duty exists under California law or the duty issue need not be reached because causation fails	Not reached (court affirmed on proximate causation grounds)
Whether Woychowski’s conduct was the proximate (legal) cause of Steinle’s death	The gun owner’s negligent storage was a but‑for cause and set in motion the events leading to the death	Intervening criminal and negligent acts by third parties made the harm unforeseeable and too attenuated for legal causation	Held: No proximate cause as a matter of law—chain of intervening acts too remote/fortuitous

Vasilenko v. Grace Fam. Church, 3 Cal. 5th 1077 (Cal. 2017) (elements of negligence including duty and proximate causation)
S. Coast Framing, Inc. v. Workers’ Comp. Appeals Bd., 61 Cal. 4th 291 (Cal. 2015) (cause in fact and proximate cause explained)
Wawanesa Mut. Ins. Co. v. Matlock, 60 Cal. App. 4th 583 (Cal. Ct. App. 1997) (attenuated chain of events can defeat proximate causation)
Shih v. Starbucks Corp., 53 Cal. App. 5th 1063 (Cal. Ct. App. 2020) (multiple intervening mishaps rendered causal link too remote)
Modisette v. Apple, Inc., 30 Cal. App. 5th 136 (Cal. Ct. App. 2018) (tenuous connection between product design and remote injuries defeats proximate causation)
Union Pac. R.R. Co. v. Ameron Pole Prods. LLC, 43 Cal. App. 5th 974 (Cal. Ct. App. 2019) (reiterating requirement of both cause in fact and legal/proximate cause)
Finocchio v. Mahler, 37 S.W.3d 300 (Mo. Ct. App. 2000) (stolen firearm cases: intervening criminal acts can break causation)
Estate of Strever v. Cline, 278 Mont. 165 (Mont. 1996) (series of intervening criminal/grossly negligent acts deemed unforeseeable; no proximate cause)